End of Regime 42 in France 2026: What E-commerce Sellers Need to Know

If you import goods into the EU via France and then dispatch them onward to customers or warehouses in another EU Member State, a key compliance change is now live.

From January 1, 2026, France has effectively ended the “one-off” fiscal representation route that many non-EU businesses used to operate Regime 42 (Customs Procedure 42 / CPC 4200) without building a full French VAT footprint. The practical outcome: many non-EU e-commerce sellers can no longer run the same “France-as-gateway” model under Procedure 42 using an intermediary’s simplified setup.

This article explains the policy change, who is affected, and the safest operational paths forward—especially for marketplace and Shopify sellers shipping under DDP (Delivered Duty Paid).

What Changed (effective Jan 1, 2026):

1. The one-off fiscal representation mechanism used for Procedure 42 by non-EU operators is no longer available.
2. One-off representative VAT numbers are no longer valid.
3. For Procedure 42 flows, freight forwarders/logisticians can no longer declare imports under their own VAT number as a one-off representative.
4. The newer import agent / international agent framework exists, but it does not cover the scope of Procedure 42 imports.

What this means in practice:

1. If you’re non-EU and you want to keep importing via France and dispatch onward under Procedure 42, you will typically need French VAT registration in your own name and ongoing French VAT reporting (and in many cases, a fiscal representative arrangement).

What is Regime 42?

Regime 42 (Customs Procedure 42 / CPC 4200) is a customs-import setup used when goods are imported into France but are not meant to stay in France—they are immediately dispatched to another EU country (for example, Germany, Italy, Spain, or the Netherlands).

In simple terms, it supports a common “EU gateway” supply chain: Import into France → clear customs → move goods onward to another EU Member State

Why sellers used Regime 42 (key benefits)

For cross-border e-commerce, Regime 42 became popular because it could offer:

1. Better cash flow at import
2. When structured correctly, import VAT is not paid upfront “in cash at the border” in France, which helps protect working capital—especially for high-volume importers.
3. A fast France-entry model for EU-wide delivery
4. Sellers could use France’s ports/air hubs and then distribute quickly across the EU, helping maintain delivery speed and marketplace performance.
5. A cleaner path for DDP shipping (seller stays the importer)
6. For sellers shipping DDP, Regime 42 aligned well with being the Importer of Record, while still allowing onward EU deliveries without stopping the goods in France.
7. Lower friction (historically) for non-EU sellers
8. Before 2026, many non-EU sellers benefited from a simplified operational route via one-off representation—making France a convenient EU entry point without building a full French VAT footprint.

What exactly changed?

France’s reform was introduced in phases:

1. The reform abolished the historic one-off tax representative mechanism and introduced a new framework for “international/import agents.”
2. Authorities provided an exceptional transition period so businesses could adapt.
3. January 1, 2026 is when the transition effectively ends: one-off representative VAT numbers are no longer valid, and the “one-off” route can no longer be used to operate Procedure 42 for non-EU businesses.

The key operational point sellers miss

Even though import VAT reverse-charge / postponed accounting concepts can make imports under other procedures financially “neutral” (cash-flow wise), some businesses continued using Procedure 42 primarily because it allowed them to appoint a forwarder/logistician under a one-off representation model. That specific capability is what is now gone.

Who is affected?

You are likely affected if you are:

1. Established outside the EU (e.g., UK, US, China, etc.), and
2. Importing into France, then dispatching onward within the EU, and/or
3. Selling DDP (you are the importer of record and carry import VAT/customs responsibilities)

EU-established operators may have different mechanisms available, but the key 2026 restriction is focused on non-EU operators and the end of the one-off representation route.

Why this matters for e-commerce operations

1) Clearance disruption risk

If your customs declarations and broker process still assume a one-off representative setup, shipments may be delayed, held, or require re-work until the correct VAT identity and reporting model is in place. That can quickly impact:

1. delivery SLAs,
2. marketplace account health metrics,
3. stock availability and replenishment cycles.

2) Compliance scope expands

Many non-EU sellers will now need a more formal footprint:

1. French VAT registration in their own name
2. Regular French VAT filings (and related reporting tied to the flow)
3. Stronger documentation controls to prove import → dispatch chain

3) Cost structure changes

Compared with the previous “simplified” approach, the new reality may include:

1. setup costs (registration and onboarding),
2. recurring compliance fees (returns/reporting),
3. fiscal representation fees where required.

What non-EU sellers can do in 2026

There isn’t one “best” option—choose based on volume, margin, delivery promise, and operational complexity.

Option 1: Keep France as your EU gateway (most stable for high volume)

If France is strategically important (carrier lanes, lead times, 3PL network, FBA France), the most straightforward solution is to formalize your French VAT position.

What it typically involves

1. French VAT registration in your company’s name
2. Broker/3PL process update (importer of record data, declaration instructions)
3. Ongoing VAT compliance and evidence controls (import docs, transport proofs, reconciliation)

Best for

1. High-volume sellers
2. DDP-first delivery models
3. Sellers optimizing for speed and consistency across EU destinations

Option 2 — Change your EU entry point (e.g., NL/BE) to optimize cash flow and process

Some sellers assess rerouting into other Member States that are known for import VAT deferment mechanisms (for example, the Netherlands “Article 23” reverse-charge on import under permit, or Belgium’s ET 14.000-style import VAT shifting).

Important operational reality

1. These mechanisms are permission-based and often require an appropriate local structure and/or tax representative arrangement.
2. They do not automatically eliminate VAT compliance obligations; they mainly change when and how import VAT is accounted for.

Best for

1. Sellers already operating through Benelux freight lanes
2. Businesses re-engineering EU fulfillment anyway (new 3PL, new warehouse geography)

Option 3 — Revisit Incoterms (DDP → DAP) to reduce seller-side obligations

Moving from DDP to DAP can shift import responsibility to the buyer.

Trade-off to consider

1. In B2C e-commerce, DAP can hurt conversion and increase customer service load due to surprise VAT/handling bills.
2. Some marketplaces restrict or discourage buyer-as-importer models depending on the program and destination.

Best for

1. B2B-heavy models
2. Low EU volume, high margin, or test-and-learn expansion phases

Action checklist

1) Map your flow

1. Where do goods enter the EU?
2. Where do they go next?
3. Are you using DDP or DAP?
4. Do you hold inventory in France or dispatch onward immediately?

2) Identify whether your 2025 process relied on one-off representation

1. Ask your broker/forwarder: Which VAT number and representation model is used for our France Procedure 42 entries?

3) Decide your 2026 route

1. Keep France (formalize VAT footprint) vs reroute entry point vs change Incoterms

4) Update broker + 3PL instructions

1. Master data, importer-of-record fields, document templates, SOPs, escalation contacts

5) Build a reporting pack

1. Minimum monthly pack: import entries, dispatch lists, transport proofs, reconciliation summary

Timing note: VAT registrations and operational onboarding can take several weeks (and longer during peak periods). If France is your gateway, start planning early to avoid disruption.

How VATAi can support

If you’re a non-EU seller importing via France, VATAi can help you:

1. confirm whether your current flow is impacted by the 2026 change
2. provide French VAT registration and ongoing reporting services where required
3. evaluate alternatives based on your delivery promise and cost model

FAQ

Q1: Did France abolish Procedure/Regime 42 completely?

In day-to-day logistics language, many providers call it the “end of Regime 42” because the simplified route non-EU sellers relied on has ended. Technically, the key change is the end of one-off fiscal representation for Procedure 42, which is what enabled many non-EU sellers to operate the model without their own French VAT footprint.

Q2: What date should we plan around?

January 1, 2026. That is the effective operational cut-off for the one-off representative VAT numbers and related simplified usage for non-EU operators.

Q3: Do non-EU sellers now need a French VAT number to keep importing via France under Procedure 42?

For many DDP and importer-of-record models, yes. To keep the France-gateway + onward EU dispatch model stable, non-EU sellers generally need French VAT registration and ongoing French VAT reporting, with fiscal representation where applicable.

Q4: Can we avoid this by rerouting via the Netherlands or Belgium?

Potentially, but it’s not a “free pass.” These countries offer import VAT deferment mechanisms that can help cash flow, but they typically require a compliant structure, permissions, and strong record-keeping. Rerouting should be evaluated as a full logistics + compliance decision.

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